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Mastering
Telehealth
Billing
Guidelines
2024:
A Blueprint for Success
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1994-2024
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LLC
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Marlene M.
Maheu
PhD
• Executive Director of Telehealth.org (formerly TBHI)
• Founder of the Journal for Technology in Behavioral
Science (JTiBS)
• Founder / CEO of the Coalition for Technology in
Behavioral Science (CTiBS)
• More than 100 hours of digitized telebehavioral
health training focused clinical, legal & ethical risk
management & compliance
• Served on a dozen professional association
committees, task forces, and workgroups related to
establishing standards and guidelines for
telebehavioral health
• Published 50+ peer-reviewed telehealth book
chapters & journal articles
• Lead author of five telehealth textbooks.
And there’s you! Please introduce yourself with state, profession and specialty.
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4
• Identify the current telehealth CPT codes
and other current telehealth billing
strategies.
• Describe what to do if you are not paid for
your telehealth sessions.
• Outline where to go to get free and
accurate information about telehealth
billing.
Learning Objectives
4
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• Slide and recording access 24/7 for 6
months. Login is required. Please respect
our copyright.
• We will continue in audio-only mode
throughout the hour.
• Please interact in chat box as I speak, but
stay on topic.
• My goal is to have a conversation with you
yet cover as much ground as possible.
• Questions asked in the course Discussion
Forum will be addressed first.
• I will stay for as long as it takes after the
hour to answer everyone’s questions.
Telehealth.org Training
5
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• LIVE CME or CE if you arrived within 15
min. of start, stay the entire time,
interact AND complete the post-test by
midnight today.
• Otherwise, you will receive a course
completion that awards you
asynchronous course credit hours.
• Social workers are invited to participate
but will not obtain CE for this hour.
Telehealth.org Training
6
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7
• I will not read all slides. Rather, I will show
you where resources are, briefly outline their
contents and invite you to review at your
discretion.
• Print handout ahead of time to take notes.
Font size options are available.
• You are automatically enrolled into our in-
house community news mailings. You can
unsubscribe at any time.
• Lock your door, turn off your phone/email, and
strap yourself in - we are about to get focused
on Optimizing Telehealth Reimbursement

Telehealth.org Training
7
Coalition for Technology
in Behavioral Science
(CTiBS)
An Interprofessional
Framework
for Telebehavioral
Health
Competencies
(2018)
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10
CTiBS TBH Competency
Domains (We will look at 3
today)
Clinical
Telepresence
Technical mHealth
Ethical &
Evidence-Based
Legal &
Regulatory
Practice
Development
7 Domains
An Interprofessional
Framework for
Telebehavioral
Health
Competencies
US Reimbursement Sources
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Private
Payers
(179M, 2021)
Medicaid &
Children’s
Health
Insurance
Program
(CHIP) (91M
Americans, 2022) Grants
Medicare (65M
Americans, 2023)
12
Private Payers (aka “Commercial
Payers” or “3rd Party Payers”)
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Typically follow the lead set
by CMS over time
Parity – mandated payment is
on par with in-person care
Payors cover different
codes in different states
Payors often “test” CPT
codes in different states
Some states require
reimbursement for
telehealth services
14
Private
Payers
Write to each payer
to ask for their
covered CPT &
modifier codes
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Always communicate in
writing
Some companies will not
respond to written inquires
Try billing one session to
get a written response
Payment can depend on state
definition of “telehealth” (phone,
video, etc.)
Some carriers don’t follow
the law
15
Private
Payers
Write to each payer
to ask for their
covered CPT and
modifier codes
Important Issues
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16
https://telehealth.org/reimbursement-for-
medicare/
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17
https://telehealth.org/medicaid-update/
Medicaid & CHIP
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19
https://telehealth.org/blog/states-
reimburse-many-aspects-of-medicaid-
telehealth-without-federal-approval/
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20
https://www.congress.gov/bill/117th-congress/house-bill/2471/text
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21
https://telehealth.org/blog/survey-findings-medicaid-telehealth-for-behavioral-
health-care/
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22
https://telehealth.org/blog/st
ates-reimburse-many-
aspects-of-medicaid-
telehealth-without-federal-
approval/
Medicaid Telehealth
Coverage Study by
Kaiser Family
Foundation
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23
https://telehealth.org/blog/medicaid-
reimbursement/
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24
24
• All 50 states and the District of
Columbia have some form of
Medicaid reimbursement for
telehealth in their public
program.
• You may need to be physically
located in the state whose
citizens you are serving
through Medicaid.
What other issues
should I know about
Medicaid paying for
telehealth?
Medicare
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27
https://telehealth.org/removal-of-requirements
for-in-person-meetings/
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28
• Clinician’s feet must be on US
soil when billing Medicare.
• Aside from that, Medicare does
not establish licensure
requirements. Such
requirements are set by state
licensing boards.
What other issues
should I know about
Medicare paying for
telehealth?
Grants
Types of Providers Eligible for
Reimbursement
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32
• Private Payers - depends on carrier,
state & profession
• Medicaid – depends on state
• Medicare - physicians, nurse
practitioners, physician assistants,
nurse midwives, certified nurse
anesthetists, clinical psychologists,
clinical social workers, registered
dietitians, MFTs, counselors, and
nutrition professionals.
• Grants – depends on grant
Who can get paid for
telehealth services?
s
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How to Search Documents
Search for the words:
“telehealth” or your
profession, such as “Social
work” by clicking “Control
F” or Command F” on your
keyboard
CPT Codes
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36
• Medicare Physician Fee Schedule
(MPFS) is released by the Centers
for Medicare and Medicaid Services
(CMS) in December
• Outlines the fees to be
reimbursed to licensed healthcare
professionals in the US.
• Telehealth.org keeps its community
informed through its blog:
https://telehealth.org/blog
Keeping up with
changes in the 2024
Physician Fee
Schedule
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37
37
Yes, for most carriers
• If you work for online
employers, they often pay
approximately $30-$35 for
hour. Many offer “signing
bonuses” as well.
• If you work for private
telehealth provider panels,
your rate can be higher than
$30 per hour.
• In many states, the law
requires insurance companies
to pay at the same rate as in-
person (known as ”telehealth
payment parity”)
Are telehealth billing
rates the same as for
in-person service
delivery?
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38
Two Types of Telehealth Parity
• Coverage or “service parity.”
Requires the same services be
covered via telehealth as would
be covered if delivered in-
person. This type of parity does
not guarantee the same rate of
payment.
• Payment parity. The same
payment rate or amount to be
reimbursed via telehealth as
would be if it had been
delivered in-person.
What does “parity”
mean with regards to
telehealth?
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39
• 9-codes often used by private
payers
• Not all payers will use the same
codes
• Payers will often pay for one code
and not another
• by American Medical Association
(AMA)
• Write to each carrier to ask which
codes they cover for telehealth
• G-codes used by Medicare,
Medicaid and CHIP (CMS)
• Grant programs may not use the
CPT coding system at all
Which CPT Codes Are
Used by Which
Payers?
* Liability Disclaimer: Verify all billing
codes with your billing professional(s)
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40
Modifier codes
• 95 - CPT Telehealth Code
Modifier
• 10 - Place of Service (POS)
What are the other key
codes used for
telehealth service?
* Telehealth.org Liability Disclaimer: Verify all
billing codes with your billing professional(s)
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41
https://www.cms.gov/Medicare/C
MS-Forms/CMS-
Forms/downloads/cms1500.pdf
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42
10 - Place of Service
(POS) code
95 - for Telehealth
after the CPT or
HCPCS code
5 Character
CPT or
HCPCS code
Telehealth
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• 98966-98988 - “Telephone assessment and management
services” provided to an established patient
• Codes may not originate from a related assessment and
management service provided within the previous 7 days
• The codes may not lead to an assessment management
service or procedure within the next 24 hours or soonest
available appointment
• Codes are to NOT be used for traditional psychotherapy
by telephone
• The codes apply only when the patient calls the provider
• “Assessment and management” does not mean formal
testing
* Liability Disclaimer: Verify all billing codes with your billing professional(s)
Audio-Only Telephone Services
43
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44
44
• 99441 CPT Code – used for audio-
only, but the 2023 Medicare
Physician Fee Schedule made it
clear that non-behavioral health
providers will not be paid for audio-
only telehealth after the PHE
• 93 – Was to be used by behavioral
professionals to the end of the PHE
• FQ – to be used by behavioral
professionals for audio-only services
with clients or patients at a distant
site after PHE (check w/ payers)
• See your “Documents” file in this
Telehealth.org training
Audio-Only (Telephone
Telehealth) Code
99441 CPT Code
rather than the 93
Modifier FQ?
* Telehealth.org Liability Disclaimer: Verify all
billing codes with your billing professional(s)
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45
https://telehealth.org/blog/making-sense-of-telephone-cpt-code-modifiers-fq-93-
the-99441-cpt-code/
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46
46
Same as in-person.
For example:
• CPT 90832 - Psychotherapy for 30
Minutes
• CPT 90834 - Psychotherapy for 45
Minutes
• CPT 90837 - Psychotherapy for
55+ Minutes
What are the CPT
codes for tele-therapy
or telebehavioral
health?
* Telehealth.org Liability Disclaimer: Verify all
billing codes with your billing professional(s)
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47
47
• “Assessment” is a term generally
used in many billing codes for in-
person care as well as when
services are delivered in-person.
• Most psychological testing and
assessment codes for telehealth are
the same as when services are
delivered in-person. (Just use in-
person codes.)
Are there telehealth-
specific assessment
codes?
* Telehealth.org Liability Disclaimer: Verify all
billing codes with your billing professional(s)
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48
48
• CPT 99483 - Cognitive Assessment
and Care Planning Services
• CPT 99334-99335 - Domiciliary,
Rest Home, or Custodial Care
services, Established patients Home
Visits, Established Patient;
developed to provide reimbursement
for comprehensive evaluation of a
new or existing patient, who exhibits
signs and/or symptoms of cognitive
impairment, is required to establish
or confirm a diagnosis, etiology and
severity for the condition.
What are examples of
cognitive assessment
codes?
* Telehealth.org Liability Disclaimer: Verify all
billing codes with your billing professional(s)
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49
49
https://telehealth.org/blog/96127-cpt-code/
Popular Telehealth Assessment Tools
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50
50
CPT 96127 - Telehealth Behavioral
Assessment
• Use in primary care offices and
other integrated care centers
• Can reimburse almost $25 per
administration and are billable up
to four times per year for the
same individual.
• Has been approved by the Center
for Medicare and Medicaid
Services Administration (CMS)
since 2015 for remote evaluations
What is a “Telehealth
Behavioral
Assessment?”
* Telehealth.org Liability Disclaimer: Verify all
billing codes with your billing professional(s)
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51
51
• CPT 90791 - Integrated
biopsychosocial
assessment, including
history, mental status, and
recommendations
• Evaluation may include “
communication with f
amily or other sources
and review and ordering
of diagnostic studies”
What are other specific
assessment billing
codes?
* Telehealth.org Liability Disclaimer: Verify all
billing codes with your billing professional(s)
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52
52
• 99453 - Remote monitoring of
physiologic parameter(s) (e.g., weight,
blood pressure, pulse oximetry,
respiratory flow rate), initial; set-up
and patient education for the use of
equipment.
• 99454 - Remote monitoring of
physiologic parameter(s) (e.g., weight,
blood pressure, pulse oximetry,
respiratory flow rate), initial; device(s)
supply with daily recording(s) or
programmed alert(s)
transmission, each 30 days.
• 99457 - Remote physiologic
monitoring treatment management
services, 20 minutes or more of
clinical staff/physician/other qualified
healthcare professional time in a
calendar month requiring interactive
communication with the
patient/caregiver during the month.
Which codes can be
used for remote patient
monitoring (RPM)?*
* Telehealth.org Liability Disclaimer: Verify all
billing codes with your billing professional(s)
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53
53
• CPT 90846 (without pt.)
• CPT 90847 (with pt.)
Which codes can be
used for family
therapy?*
* Telehealth.org Liability Disclaimer: Verify all
billing codes with your billing professional(s)
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54
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55
https://telehealth.hhs.gov/providers/telehealth-for-behavioral-health/billing-for-
telebehavioral-health/
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56
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** Included in your
“Documents”file for this course
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58
58
• Telephone CPT G2252 or bill as
you would in-person
• Telesupervision – “Incident to”
through the PHE
• Virtual Check-Ins CPT G2012
• Remote patient monitoring
(RPM) Code 99091+ Others
What are the specific
billing codes for
telehealth?*
* Liability Disclaimer: Verify all billing
codes with your billing professional(s)
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59
59
• No clear CPT code for
“Telesupervision”
• 99449 - Interprofessional
Telephone/Internet/Electronic
Health Record Consultations -
Time spent by a consultant who
is not in direct contact with the
patient at the time of service
What are other specific
billing codes for
telehealth?*
* Liability Disclaimer: Verify all billing
codes with your billing professional(s)
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60
60
• CPT 90853 – Group Intervention
• CPT 96165 (Group Intervention
for each additional 15 minutes)
What are the specific
billing codes for group
telehealth?*
* Liability Disclaimer: Verify all billing
codes with your billing professional(s)
Four Little-Used Telehealth-
Specific Billing Codes
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Additional Telehealth Billing Codes
E-Visit E-Consult
Virtual
Check-in
Facility Fee
• Inter-
professional
• Patient contact
initiated by
professional or
staff
• Billed by
professional
office serving
as patient site
• Initiated by
patient through
portal
62
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63
What is an E-Visit?
E-Visits are non-face-to-face services
conducted online, or through email,
text, telephone, electronic health
record (EHR) portal messages or
other HIPAA-compliant, secure
platforms.
They are also known as “online
assessment and management
services” that require the professional
to assess and make decisions about
answers to further manage the patient.
They are always patient-initiated.
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https://www.apaservices.org/practice/reimbursement/health-codes/online-
assessment-management-services
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65
65
Who Initiates an E-
Visit?
E-Visits Are Always Patient-Initiated
They can involve the time needed to:
• Review the initial inquiry
• Review records
• Interact with clinical staff about the
patient’s question
• Development of a management plan
• Involves feedback on functioning,
treatment changes and planning
for monitoring and follow-up
• Subsequent digital communication
online, email, texting, telephone,
etc.
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66
E-Visit Details
• Must be more than five minutes.
• Report e-visit services once per
seven-day period.
• Do not count G2061, G2062 or
G2063 time otherwise reported
with other services.
• Do not use e-visit service codes
if the initial inquiry from the
patient comes within seven
days of a previous treatment or
service that both relate to the
same problem.
What are the details
related to E-Visit
Codes?
* Telehealth.org Liability Disclaimer: Verify all
billing codes with your billing professional(s)
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67
E-Visit Details
• Do not use e-visit service codes if
the initial inquiry from the patient
occurs within the post-treatment
period of a previously completed
procedure.
• If the initial inquiry from the patient
comes within seven days of another
treatment or assessment service,
you can only use e-visit service
codes if the inquiry addresses
a different problem.
• If the patient presents a new,
unrelated problem within the seven-
day period of an e-visit service, add
time spent on the assessment and
management of the additional
problem to the cumulative service
time.
What more do I need to
know about E-Visit
Codes?
* Telehealth.org Liability Disclaimer: Verify all
billing codes with your billing professional(s)
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68
E-Visit Details
• Can be covered by some payers
and not others.
• Confirm access to these codes
with all involved payers prior to
using.
What more do I need to
know about E-Visit
Codes?
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69
69
E-Visit Codes
• G2061- Qualified health care
professional online assessment
and management service, for an
established patient, for up to
seven days, cumulative time 5-
10 minutes
• G2062 - cumulative time 11-20
minutes
• G2063 - cumulative time 21 or
more minutes
What are E-Visit
codes?*
* Telehealth.org Liability Disclaimer: Verify all
billing codes with your billing professional(s)
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70
70
E-Consult
• Can be covered by some payers
and not others.
• Confirm access to these codes
with all involved payers prior to
using.
What is an E-Consult?
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71
E-Consult
• Known as electronic consultations
or interprofessional consults, are
communications between health
care providers.
• Providers can interact with each
other by using phone, video, or a
HIPAA-compliant platform that
allows two-way communication
and can securely share patient
records.
What is an E-Consult?
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72
E-Consult
• 99446, 99447, 99448, 99449 -
Verbal and written report
• 99451 - Written report only
What are the billing
codes for E-Consults?
* Telehealth.org Liability Disclaimer: Verify all
billing codes with your billing professional(s)
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• Two new billing codes will be introduced so that providers can
bill for virtual check-ins and remote evaluation of patient-
submitted video or images.
• Virtual Check-in (HCPCS Code G2012)
• Store-and-Forward (HCPCS code G2010 )
• Provider and patient must be in different geographic locations
• Only for patients who have an established (or existing)
relationship with a physician or certain practitioners where the
communication is not related to a medical visit within the
previous 7 days and does not lead to a medical visit within the
next 24 hours (or soonest appointment available).
Virtual Check-Ins
73
* Telehealth.org Liability
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codes with your billing
professional(s)
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• The patient must verbally consent to receive virtual check-in
services. The Medicare coinsurance and deductible would
generally apply to these services.
• Doctors and certain practitioners may bill for these virtual check
in services furnished through several communication technology
modalities, such as telephone (HCPCS CPT G2012).
• The practitioner may respond to the patient’s concern by
telephone, audio/video, secure text messaging, email, or use of
a patient portal.
* Telehealth.org Liability Disclaimer: Verify all billing codes with your billing
professional(s)
Virtual Check-Ins
74
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75
• An e-visit is when a client or
patient communicates with their
health care provider through an
online patient portal.
• A virtual check-in is billed bill for
brief (5-10 minute)
communications that mitigate the
need for an in-person visit.
Difference between E-
Consults & Virtual
Check-ins?
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• Definition
• Telehealth originating
site facility fee
• Who can collect
• Originating site only
• Site must bill
• Not the practitioner
• HCPCS code Q3014
What is a facility fee
and which telemedicine
CPT code can be used
to collect it?
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https://data.hrsa.gov/tools/m
edicare/telehealth
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78
• Visit Complexity Inherent to Certain
Office/Outpatient E&Ms HCPCS
G2211
• Prolonged Services HCPCS G2212
• Psychological and
Neuropsychological Testing CPT
96121
What are the specific
Medicare telehealth
billing codes that are
now permanent?
* Telehealth.org Liability Disclaimer: Verify all
billing codes with your billing professional(s)
Other Legal Issues of
Relevance to Reimbursement
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rights
reserved.
80
• Practicing over state lines is
illegal and subject to a variety of
monetary fines and/or
imprisonment for up to one year,
depending on the state.
• When signing the “1500 form”
your signature attests to the fact
that you are aware of your legal
mandates and are following
them all.
• Insurance fraud is not taken
lightly by many boards, and
penalties can be steep.
Why is
interjurisdictional
practice an issue in
telehealth
reimbursement?
©
1994-2024
Telehealth.org,
LLC
All
rights
reserved.
81
Yes - if you are properly:
• Licensed
• Registered
Can you get reimbursed
for delivering care to
someone over state lines
or international borders?
©
1994-2024
Telehealth.org,
LLC
All
rights
reserved.
82
• Medicare has gone on record
saying that it will not “go back”
• Several bills in Congress at the
federal level to make Medicare
reimbursement for telehealth
more permanent.
• See telehealth.org/blog for
details.
Who are the best
payers to consider
when planning a
telehealth focus for
your practice?
©
1994-2024
Telehealth.org,
LLC
All
rights
reserved.
83
What are state payers
doing now?
Let’s Discuss – What
Can You Offer to the
Group?
©
1994-2024
Telehealth.org,
LLC
All
rights
reserved.
84
• Disabled populations
• Nursing homes and adult care
facilities
• Health-related behavioral
disorders
• Substance use disorders
What are the best
Medicare and Medicaid
opportunities now?
©
1994-2024
Telehealth.org,
LLC
All
rights
reserved.
85
• Dependent on
• State
• Insurance company (carrier)
• Diagnosis
Are out-of-network
providers also being
covered for telehealth
services?
©
1994-2024
Telehealth.org,
LLC
All
rights
reserved.
86
• Contact the company
• No universal practice –the
solution depends on the
company
• Resubmit with an explanation
• Some companies will not
accept repeated submissions
• EHR issues
How can you correct a
claim if you made
errors?
©
1994-2024
Telehealth.org,
LLC
All
rights
reserved.
87
• CMS Newsroom
• Center for Connected Health
Policy (CCHP)
• Telehealth.HHS.GOV
• Regional Telehealth resource
Centers
• Telehealth.org Blog, Newsletter,
Directory
Where to get up-do-
information about
telehealth
reimbursement in
different states?
IMPORTANT ISSUE
©
1994-2024
Telehealth.org,
LLC
All
rights
reserved.
https://www.cms.gov/n
ewsroom/
©
1994-2024
Telehealth.org,
LLC
All
rights
reserved.
89
Center for Connected Health Policy https://www.cchpca.org/
Center for Connected Health Policy - https://www.cchpca.org/
©
1994-2024
Telehealth.org,
LLC
All
rights
reserved.
92
https://telehealth.hhs.gov/providers/telehealth-for-
behavioral-health/billing-for-telebehavioral-health/
©
1994-2024
Telehealth.org,
LLC
All
rights
reserved.
93
https://telehealth.org/blog
©
1994-2024
Telehealth.org,
LLC
All
rights
reserved.
94
https://telehealth.org/blog
©
1994-2024
Telehealth.org,
LLC
All
rights
reserved.
95
https://telehealth.org/signup/
©
1994-2024
Telehealth.org,
LLC
All
rights
reserved.
96
http:/directory.telehealth.org
©
1994-2024
Telehealth.org,
LLC
All
rights
reserved.
97
https://directory.telehealth.org/cat
egories/billing-revenue-
cycle/?classified_sortby=title_asc
Any
Questions
?
See our other
programs! ☺
Telehealth.org/course-catalog
contact@telehealth.org
619-255-2788
Marlene M. Maheu, PhD

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